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Court Considers Massachusetts Manslaughter Case Involving Defendant’s Failure to Put Children in Car Seats

In June 2019, the Supreme Judicial Court of Massachusetts issued an opinion in a Massachusetts manslaughter case involving the defendant’s failure to put her two nephews in age-appropriate car seats. The court ultimately reversed most of the defendant’s convictions, finding that the prosecution failed to establish the defendant’s conduct was reckless or wanton.

According to the court’s opinion, the defendant was involved in a multi-vehicle accident in which her two nephews – aged four and 16 months – were fatally injured. The defendant and her four-year-old son were injured, but survived. At the time of the accident, the four-year-old was in the back seat with the seatbelt strapped but without a car seat; the 16-month-old child was in a front-facing car seat with the straps set too high.

The defendant was indicted on two counts of manslaughter, two counts of negligent motor vehicle homicide, and three counts of reckless endangerment of a child. The defendant was later convicted of two counts of reckless endangerment, one count of manslaughter, and one count of negligent motor vehicle homicide. The defendant appealed, arguing that she lacked the necessary mental state to find her guilty of manslaughter and reckless endangerment.

The court agreed with the defendant, and reversed her convictions for manslaughter and reckless endangerment. The court explained that each of these charges requires a showing that the defendant was at least reckless. Recklessness, the court explained, can be established through an omission to act, which was the prosecution’s theory in this case; however, given the facts as they were presented, the court determined that no rational juror could find that the defendant acted recklessly.

The court acknowledged the prosecution’s expert witness testimony which stated that the defendant’s inattentiveness was the cause of the accident. However, the court explained that the prosecution must show more than mere negligence to reach a finding of recklessness. The prosecution tried to meet their burden by showing that the defendant failed to strap the children into proper car seats. Again, the court had no issue with labeling the defendant’s conduct negligent, but held that it did not reach of level of recklessness. The court explained that to find otherwise would equate to holding “that operating a motor vehicle with an improperly restrained child is per se an inherently dangerous activity, even absent other factors that enhance its dangerousness.” The court explained that “recklessness is more than a mistake of judgment or even gross negligence.” The court also rejected the prosecution’s argument that the “totality of the circumstance” showed the defendant’s recklessness.

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